Information on the processing of personal data pursuant to Article 13 of EU Regulation 2016/679

Dear Customer,

We provide below, in accordance with the provisions of European legislation on the processing of personal data, the information required by Article 13 of EU Regulation 2016/679 on the processing of data following your decision to activate vehicle telematics on your Askoll vehicle and to install the app on your smartphone.

The data controller is the company Askoll EVA S.p.A., Via Industria, 30 36031 Dueville VI – Tel. (+39) 0444 920260 – email askoll@askoll.com.

Data processed: Through telematics and through the app, information relating to the connected vehicle is collected and processed, including:

1. a) Vehicle geolocation: the current position of the vehicle, used to determine the routes travelled and – if the relevant function has been activated in the App – to report suspicions that the vehicle has been stolen
2. b) Driving data: the operation and use of the vehicle
3. c) Vehicle data: vehicle status, performance and diagnostics (including kilometres travelled, recharging data, battery level and range, CO2 saved, warning and error codes, etc.)

Please note that once telematics is activated, it is not possible to temporarily exclude or deactivate geolocalisation. If the user does not want geolocalisation to be detected and processed, he must contact an authorised dealer in order to deactivate telematics.

The app also processes the identifying data of the user concerned, such as personal data such as the user’s e-mail address and the identifying information of the electric vehicle used by the user and connected to the app. All the data requested are indispensable to guarantee the regular use of the app and/or the usability of the accessory functions connected to it.

Purposes and legal bases of the processing

1. to provide functions and services to the user and in particular to allow, through the activation of telematics and the use of the App, the continuous control of specific functions of the vehicle to which it is connected by means of communication with the telematics and the vehicle’s control unit, including the geolocation system of the vehicle in which the telematics is installed and which records the routes travelled by the vehicle; this processing, although based on the performance of the contractual performance to which the Controller is bound following the user’s decision to activate the vehicle telematics and use the App on his smartphone, is by the Controller’s choice based on consent; such consent is not mandatory, but failure to consent shall affect the possibility of activating the telematics, installing the App and thus offering any of the App’s services
2. to enable the Controller to carry out anonymised statistical analyses relating to the use of vehicles and their operation, quality and defectiveness for the purpose of product improvement, by processing certain data such as driving data and vehicle data (such as total kilometres, diagnostic data, average speed and average kilometres travelled). The legal basis for this processing is our justified interest in the improvement of our offer; however, we prefer to ask for consent, which is incidental and optional, with the understanding that lack of consent does not affect the functionality of point a);
3. to allow, should the user so desire, the data controller to send newsletters and other marketing communications to the same, using for this purpose the e-mail address provided during activation of the app; this processing is accessory and optional and failure to do so will not affect the functionality of point a).

The user has the right to change his or her choices at any time with regard to the purposes referred to in points b) and c). It is also noted that the functions of the smartphone allow the user to manage the connections between the app and the different functions of the smartphone.

Recipients of the data: the data subject to processing will not be communicated or disseminated to third parties except to the subjects, located within the European Union and appointed as data processors, who manage the storage of the data, the servers and computer systems of the telematics and app and the maintenance of the computer systems used for processing. It should be noted that no person has access to the data generated by the use of the app (operation of the vehicle and routes travelled) unless this is strictly necessary to carry out system maintenance activities.

Period of data retention: data will be stored for as long as the user subscribes to and uses the app or until the user requests that the data be deleted.

The data will be deleted if you do not renew your subscription when it expires or if you delete the app from your device, as detailed below.

Once the subscription has expired, without the subscription having been renewed, telematics ceases to collect and transmit data. The process of deleting the data stored in the remote processing systems is carried out using the following procedure:

1. a) 1 month before the subscription expires, an email will be sent warning that in order to keep the telematics and related services active, the subscription must be renewed by its expiry date;
2. b) After a further 15 days, another warning email will be sent and at the end of the last month of validity of the subscription, without the subscription having been renewed (non-renewal obviously implying the user’s decision to delete the information relating to its use), a final email will be sent to inform of the deletion of the data;
3. c) the data will be deleted within 30 days following the expiry of the subscription.

If the user proceeds with the deletion of his account or the app from his device, as there is no functionality available to detect the deletion of the app, the deletion of the data stored in the remote processing systems will take place on the expiry of the subscription, according to the procedure described above.

In all cases for reasons of guaranteeing continuity of service (e.g. in the event of a future request for reactivation of the user), the deleted data are blocked and are therefore no longer available for further use, in particular for the use of services, and remain stored on the system’s “backup” archives for 10 years and are not subject to any other or further processing.Dopo l’eliminazione e la cancellazione dei relativi backup non sarà possibile in alcun modo recuperare i dati.

Rights of access, rectification and deletion: all data acquired and processed are directly accessible to the user using the app functions. The user can make changes to certain master data. The data provided by the user are not changed and further data managed by the app are acquired by automatic systems and are therefore correct, except in the event of a malfunction. In addition, rights may be exercised by submitting a request to the data controller at one of the above-mentioned contact points.

Right to complain: if you believe that your personal data is being processed in a manner that does not comply with the relevant legislation, you have the right to appeal to a supervisory authority, in Italy the Data Protection Authority.